**Wigberto “Toby” R. Tañada, Jr. vs. House of Representatives Electoral Tribunal, Angelina “Helen” D. Tan, and Alvin John S. Tañada**
Facts:
In the 2013 National and Local Elections for the position of Representative of the Fourth Legislative District of the Province of Quezon, three candidates filed their Certificates of Candidacy (CoCs), namely, petitioner Wigberto R. Tañada, Jr. (Wigberto) of the Liberal Party, respondent Angelina D. Tan (Tan) of the Nationalist People’s Coalition, and respondent Alvin John S. Tañada (Alvin John) of Lapiang Manggagawa.
Wigberto filed petitions in the Commission on Elections (COMELEC) to cancel Alvin John’s CoC and to declare him a nuisance candidate. The COMELEC First Division dismissed the petitions for lack of merit, but upon Wigberto’s motion for reconsideration, the COMELEC En Banc canceled Alvin John’s CoC while maintaining he was not a nuisance candidate.
During the elections, the name of Alvin John remained on the ballots, and after votes were canvassed, Tan emerged as the winner. Wigberto then sought to correct this by arguing that the votes for Alvin John should be consolidated in his favor, but his motions were denied, and Tan was proclaimed the winner.
Wigberto subsequently filed an election protest with the House of Representatives Electoral Tribunal (HRET), alleging fraud through the fielding of Alvin John as a nuisance candidate to sabotage his candidacy. He contested the miscounting and mistabulation of votes allegedly cast for him as votes for Alvin John.
The COMELEC eventually annulled Tan’s proclamation and directed the credit of Alvin John’s votes to Wigberto. However, since Tan had assumed office, the decision became moot.
Wigberto then raised the issue in the Supreme Court under G.R. Nos. 207199-200, but the Court dismissed his petition, directing him to the HRET to question the conduct of the canvass and Tan’s proclamation. The HRET dismissed Wigberto’s protest, stating insufficiency in form and substance, and clarified that it does not have jurisdiction over nuisance candidate declarations.
Issues:
1. Whether the HRET correctly limited its jurisdiction in election protests as defined by the Constitution, law, and jurisprudence.
2. Whether the HRET can be limited to the opening of ballot boxes and revision of ballots in an election protest.
3. Whether the HRET can examine the fraudulent fielding of a nuisance candidate and whether it has the power to review, modify, or reverse the factual finding of the COMELEC on nuisance candidates.
Court’s Decision:
The Supreme Court affirmed the HRET’s dismissal of Wigberto’s election protest for the following reasons:
1. Wigberto filed prohibited pleadings post the allowed period, making the COMELEC En Banc’s resolution final and executory and precluding him from raising Alvin John’s nuisance candidacy as an issue in other forums.
2. The HRET properly declared that it has no jurisdiction to determine whether Alvin John was a nuisance candidate.
3. The Supreme Court dismissed Wigberto’s assumption that the HRET may reverse the COMELEC’s findings on nuisance candidacy, as the HRET does not have appellate jurisdiction over COMELEC resolutions.
4. The Court clarified its previous directive to Wigberto to approach the HRET was to question the conduct of the canvass and Tan’s proclamation.
Doctrine:
The House of Representatives Electoral Tribunal (HRET) has limited jurisdiction over election protests and quo warranto cases concerning “election, returns, and qualifications of their respective Members,” and does not extend to the review of COMELEC’s determination on nuisance candidacy.
Historical Background:
The case presents the intersection of electoral law, judicial review, and the separation of powers between the COMELEC and the HRET concerning jurisdiction over election-related issues in the Philippines. The factual background involves a Constitutional mandate, COMELEC’s administrative power over elections, and the exclusive jurisdiction of the HRET over the election of House members, shaping an essential precedent for electoral jurisprudence. The historical context emphasizes the importance of delineating responsibilities between electoral and legislative bodies in a democratic framework to safeguard the electoral process’s integrity.
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